Roy v. Bath Iron Works: Three Different Perspectives on an Unfortunate Situation

Joseph Roy was an employee of Bath Iron Works (BIW) who suffered work-related injuries to his lower back in 1987 and to his neck in 1994 In 2005, Roy filed a petition for review of his workers\u27 compensation benefits and sought, among other benefits, total incapacity benefits because his neck injury had worsened. A hearing officer from the Workers\u27 Compensation Board found that Roy\u27s work-related injuries had totally incapacitated him, but denied Roy total incapacity benefits after March 6, 2006, because a non-work-related liver condition had also caused him to become totally incapacitated. Roy appealed the decision to the Maine Supreme Judicial Court, sitting as the Law Court, and argued that under Maine law, subsequent non-work-related injuries in workers\u27 compensation cases do not relieve the employer of responsibility for a co-existing total incapacity caused by work-related injuries. In Roy v. Bath Iron Works, the Law Court vacated and remanded the hearing officer\u27s decision. Writing for the majority, Justice Alexander found that the language of title 39-A, section 201(5) of the Maine Revised Statutes was unambiguous and that the statute said nothing about eliminating workers\u27 compensation due to subsequent non-work related injuries. Justices Levy and Clifford, concurring with the majority, asserted that recent amendments to Maine\u27s workers\u27 compensation law subsumed the independent intervening cause doctrine. Furthermore, the concurrence found that even if the statutes had not eliminated the doctrine, the hearing officer\u27s decision was still incorrect because Roy\u27s work-related injury remained a substantial cause of his incapacity. In her dissent, Justice Gorman contended that the hearing officer\u27s determination should be affirmed because (1) the underlying purpose of workers\u27 compensation is to replace wages when an employee is unable to earn income after a work injury, and (2) Roy\u27s liver condition was an independent intervening cause that cut off a prior award for total incapacity benefits. The court\u27s narrow four-to-three decision turned on which legal concept- statutory interpretation or underlying purpose and independent intervening causes- should be applied to the facts of this case to produce the fairest result